To: [RECORDS CONTACT]
cc: [CLERK]; [CITY ATTORNEY]; [CHIEF]
Subject: [STATE] public records: status of my [DATE] requests, itemized list of records not yet received (Items 1 through [N])
Date: [DATE]
Dear [RECORDS CONTACT]:
Thank you for the records the City has produced to date. This letter does three things. It acknowledges what I have received, it provides an itemized list of the records requested on [DATE] that have not yet been received, and it identifies [two] deficiencies that need correction. Under [CITATION], responses to the [DATE] requests were due by [DUE DATE]. I am not treating the delay as bad faith; I am asking that the outstanding items now be completed, and this list is intended to make that easy.
Received to date, with thanks: [list each production by date and description, in neutral terms].
So that the record is orderly, one housekeeping request first:
1. For each production delivered to date, an itemized statement identifying which of my lettered requests and which numbered items that production responds to, and whether the production for that item is complete or partial. If any production was intended as complete for a given custodian, please say so in writing for that custodian.
Records requested [DATE] and not yet received, itemized:
2. The executed agreement. The agreement produced is an unsigned draft dated [DATE] with a blank signature page. Please produce the fully executed order form and agreement, including every signature, name, title, date, and purchase-order number, and the e-signature certificate of completion if one exists. If no fully executed copy exists in the City's possession, please state that in writing.
3. The production gap. Documents numbered [70] and [101 through 120] of the [DATE] production are missing. Please produce them, or state in writing why each was withheld, citing the specific exemption, and release any segregable portion.
4. [CUSTODIAN]'s records, [MONTH] through [MONTH]. My request covered communications from [START DATE] forward for all custodians. The production from [CUSTODIAN]'s mailbox begins [DATE]. Records produced from other custodians show responsive correspondence to and from [CUSTODIAN] throughout [PERIOD]. Please produce [CUSTODIAN]'s responsive records for that period.
5. [Letter X, item Y]. [One sentence restating the item.] Not received.
6. [Letter X, item Z]. [One sentence.] Not received.
7. The [DATE] denial letter. The one-page response citing “[QUOTED EXEMPTION LANGUAGE]” does not identify which request it responds to, the records withheld, or how the exemption applies to them. Please identify the request and items it was intended to answer; identify each record withheld; state whether [an investigation] is in fact open as to each; and produce the segregable remainder as [CITATION] requires.
A written “no such record exists” is a complete and acceptable answer for any numbered item, and where that is the case it is the answer I am asking for. My [DATE] request concerning [OTHER SUBJECT] remains pending on its own clock and is not superseded by this letter.
[PASTE THE STANDING-REQUESTS BLOCK]
Respectfully,
[YOUR NAME] · [ADDRESS] · [PHONE] · [EMAIL]